IR 05000244/2012009
| ML12311A124 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 11/05/2012 |
| From: | Chris Miller Division of Reactor Safety I |
| To: | Joseph Pacher Constellation Energy Nuclear Group |
| References | |
| EA-12-209 EA-12-209, IR-12-009 | |
| Download: ML12311A124 (32) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 21OO RENAISSANCE BOULEVARD, SUITE 1OO
SUBJECT:
R.E. cINNA NUCLEAR POWER PLANT - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT O5OOO244I2O12OO9 AND EXERCISE OF ENFORCEMENT DISCRETION
Dear Mr. Pacher:
On September 28, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed a triennial fire protection inspection at your R.E. Ginna Nuclear Power Plant. The enclosed inspection report documents the inspection results, which were discussed on September 28, 2012, wilh you and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations, and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed station personnel. The inspectors also reviewed mitigation strategies for addressing large fires and explosions.
Based on the results of this inspection, two findings, identified by the NRC, were issued. These findings were also determined to be violations of a Ginna fire protection license condition. The NRC screened these findings and determined that they warranted enforcement discretion per Section 9.1 of the NRC Enforcement Policy, "Enforcement Discretion for Certain Fire Protection lssues (10 CFR 50.48)."
lf you contest any non-cited violation in this report, you should provide a written response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington D.C. 20555-0001; with copies to the Regional Administrator, Region l; the Director, Office of Enforcement; and the NRC Senior Resident Inspector at R.E. Ginna Nuclear Power Plant. ln accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390 of the NRC's
"Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of the NRC's document system, Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.oov/readinq-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
.)
/HDLG-
"Christopher G. Miller, Director Division of Reactor Safety Docket No: 50-244 License No: DPR-18
Enclosure:
Inspection Report 0500024412012009 w/Attachment: Supplemental Information
REGION I Docket No: 50-244 License No: DPR-18 Report No: 0500024412012009 Licensee: Constellation Energy Nuclear Group, LLC Facility: R.E. Ginna Nuclear Power Plant, LLC Location: Ontario, New York Dates: September lQ to 28,2012 Inspectors: J. Richmond, Senior Reactor Inspector (Team Leader)
W. Cook, Senior Reactor AnalYst R. Fuhrmeister, Senior Reactor lnspector D. Orr, Senior Reactor Inspector A. Dugandzic, Project Engineer Approved by: John F. Rogge, Chief Engineering Branch 3 Division of Reactor Safety Enclosure
SUMMARY OF FINDINGS
lR 0500024412012009:0911012012 - A912812012; R.E, Ginna Nuclear Power Plant; Triennial
Fire Protection Inspection.
This report covered a two week on-site triennialfire protection team inspection by specialist inspectors. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.
No findings were identified for assessment.
REPORT DETAILS
Backqround This report presents the results of a triennial fire protection inspection conducted in accordance with NRC Inspection Procedure (lP) 71 1 1 1.05T, "Fire Protection." The objective of the inspection was to assess whether Constellation Energy Nuclear Group (Constellation) had implemented an adequate fire protection program, and whether posffire safe shutdown capabilities had been established and were properly maintained at R.E. Ginna Nuclear Power Plant (Ginna). The following fire areas and associated fire zones were selected for detailed review based on prior inspection results and risk insights from the Ginna Individual Plant Examination of External Events (IPEEE):
Fire Areas and/or Fire Zones o Fire Zone ABB, Auxiliary Bldg Basement, Elevation (Elev.) 235 ft.
.
Fire Area BR1B, 1B Battery Room, Elev. 253 ft.
o Fire Area EDG1A, 1A Emergency Diesel Generator (EDG) room, including the 1A EDG Cable Vault. Elev. 253 ft.
Inspection of these fire areaslzones fulfilled the inspection procedure requirement to inspect a minimum of three samples.
The inspection team evaluated Constellation's fire protection program (FPP) against applicable requirements which included Technical Specifications, Operating License Condition 2.C.(3),
NRC Safety Evaluation Reports (SER), Title 10 of the Code of Federal Regulations (10 CFR) 50.48, and 10 CFR Part 50, Appendix R, and Branch Technical Position (BTP)
Auxiliary and Power Conversion Systems Branch (APCSB) 9.5-1 and Appendix A. The team also reviewed related documents that included the Updated Final Safety Analysis Report (UFSAR), Section 9.5.1, fire protection plan, firehazards analysis (FHA), and post-fire safe shutdown analyses.
The team evaluated aspects of three mitigating strategies for responding to large fires and explosions, which are required by Operating License Condition 2.C.(8), and 10 CFR 50.54(hhx2). The team also reviewed related documents that included NEI 06-12, "8.5.b Phases 2 & 3 Submittal Guidance," Revision 2 (ML070090060). Inspection of these strategies fulfills the inspection procedure requirement to inspect a minimum of one sample.
Specific documents reviewed by the team are listed in the attachment to this report, REACTOR SAFEW Initiating Events, Mitigating Systems, and Barrier lntegrity
1R05 Fire Protection (lP 711 11.05T)
.01 Protection of Safe Shutdown Capabilities
a. lnspection Scope The team reviewed the FHA, post-fire safe shutdown analyses, and supporting drawings and documents to verify whether the safe shutdown capabilities were properly protected from fire damage. The team evaluated equipment and cable separation to determine whether applicable separation requirements of Section lll.G of 10 CFR 50, Appendix R, and the Ginna design and licensing bases were maintained for the credited safe shutdown equipment and their supporting power, control, and instrumentation cables.
The team's review included an assessment of the adequacy of the selected systems for reactor pressure control, reactivity control, reactor coolant makeup, decay heat removal, process monitoring, and associated support system functions.
b. Findinqs No findings were
.02 Passive Fire Protection
a. Inspection Scope
The team walked down accessible portions of the selected fire areas to evaluate whether the material conditions of the fire area boundaries were adequate for the fire hazards in the area. The team compared the fire area boundaries, including walls, ceilings, floors, fire doors, fire dampers, penetration seals, electrical raceway and conduit fire barriers, and redundant equipment fire barriers and radiant energy heat barriers to design and licensing basis requirements, industry standards, and the Ginna FPP, as approved by the NRC, to identify any potential degradation or non-conformances.
The team reviewed selected engineering evaluations, installation work orders, and qualification records for a sample of penetration seals to determine whether the fill material was properly installed and whether the as-left configuration satisfied design requirements for the intended fire rating. The team also reviewed similar records for selected fire protection wraps to verify whether the material and configuration was appropriate for the required fire rating and conformed to the engineering design.
The team also reviewed recent inspection and functional test records for fire dampers, and the inspection records for penetration seals and fire barriers, to verify whether the inspection and testing was adequately conducted, the acceptance criteria were met, and any potential performance degradation was identified.
b. Findinqs No findings were
.03 Active Fire Protection
a. Inspection Scope
The team evaluated manual and automatic fire suppression and detection systems in the selected fire areas to determine whether they were installed, tested, maintained, and operated in accordance with NRC requirements, National Fire Protection Association (NFPA) codes of record, and the Ginna FPP, as approved by the U,S. Nuclear Regulatory Commission (NRC), The team also assessed whether the suppression systems capabilities were adequate to control and/or extinguish fires associated with the hazards in the selected areas.
The team reviewed the as-built capability of the fire water supply system to verify whether the design and licensing basis and NFPA code of record requirements were satisfied, and to assess whether those capabilities were adequate for the hazards involved. The team reviewed the fire water system hydraulic analyses to assess the adequacy of a single fire water pump to supply the largest single hydraulic load on the fire water system plus concurrent fire hose usage. The team evaluated the fire pump performance tests to assess the adequacy of the test acceptance criteria for pump minimum discharge pressure at the required flow rate, to verify whether the criteria was adequate to ensure that the design basis and hydraulic analysis requirements were satisfied. The team also evaluated the underground fire loop flow tests to verify whether the tests adequately demonstrated that the flow distribution circuits were able to meet design basis requirements. In addition, the team reviewed recent pump and loop flow test results to verify whether the testing was adequately conducted, the acceptance criteria were met, and any potential performance degradation was identified.
The team walked down accessible portions of the detection and water suppression systems in the selected areas and major portions of the fire water supply system, including motor and diesel driven fire pumps, interviewed system and program engineers, and reviewed selected condition reports (CR) to independently assess the material condition of the systems and components. In addition, the team reviewed recent test results for the fire detection and suppression systems for the selected fire areas to verify whether the testing was adequately conducted, the acceptance criteria were met, and any potential performance degradation was identified' The team assessed the fire brigade capabilities by reviewing training, qualification, and drill critique records. The team also reviewed Constellation's fire fighting strategies (i.e.,
pre-fire plans) and smoke removal plans for the selected fire areas to determine if appropriate information was provided to fire brigade members and plant operators to identify safe shutdown equipment and instrumentation, and to facilitate suppression of a fire that could impact post-fire safe shutdown capability. The team independently inspected the fire brigade equipment, including personnel protective gear (e,9., turnout gear) and smoke removal equipment, to determine operational readiness for fire fighting.
In addition, the team observed an announced fire brigade training drill, including Constellation's post drill critique.
Findinqs No findings were identified.
.04 Protection from Damase from Fire Suppression Activities
lnspection Scopg The team performed document reviews and plant walkdowns to determine whether redundant trains of systems required for hot shutdown, located in the same or adjacent fire areas, were not subject to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems. Specifically, the team evaluated whether:
A fire in one of the selected fire areas would not release smoke, heat, or hot gases that could cause unintended activation of suppression systems in adjacent fire areas which could potentially damage all redundant safe shutdown trains; or A fire suppression system rupture, inadvertent actuation, or actuation due to a fire, in one of the selected fire areas, could not directly damage all redundant trains (e.g., sprinkler caused flooding of other than the locally affected train); and o Adequate drainage was provided in areas protected by water suppression systems.
b. Findinqs No findings were identified.
.05 Alternative Shutdown Capabilitv
Inspection Scope The team reviewed the safe shutdown analysis, operating procedures, piping and instrumentation drawings (P&lD), electrical drawings, the UFSAR, and other supporting documents for the selected fire areas to verify whether Constellation had properly identified the systems and components necessary to achieve and maintain post-fire safe shutdown conditions. The team evaluated selected systems and components credited by the safe shutdown analysis for reactor pressure control, reactivity control, reactor coolant system (RCS) makeup, decay heat removal, process monitoring, and support system functions to assess the adequacy of Constellation's alternative shutdown methodology. The team also assessed whether alternative post-fire shutdown could be performed both with and without the availability of off-site power. The team walked down selected plant configurations to verify whether they were consistent with the assumptions and descriptions in the safe shutdown and fire hazards analyses. ln addition, the team evaluated whether the systems and components credited for use during post-fire safe shutdown would remain free from fire damage.
The team reviewed the training program for licensed and non-licensed operators to verify whether it included alternative shutdown capability. The team also verified whether personnel required for post-fire safe shutdown, using either the normal or alternative shutdown methods, were trained and available on-site at all times, exclusive of those assigned as fire brigade members.
The team reviewed the adequacy of procedures utilized for post-fire shutdown and performed an independent walk through of procedure steps (i.e., a procedure tabletop)to assess the adequacy of implementation and human factors within the procedures.
The team also evaluated the time required to perform specific actions to verify whether operators could reasonably be expected to perform those actions within sufficient time to maintain plant parameters within specified limits.
Specific procedures reviewed for normal and alternative post-fire shutdown included:
o ER-Fire.O, Control Room Response to Fire Alarms and Reports;
. ER-Fire.3, Alternate Shutdown for Aux Building BasemenVMezzanine Fire;
. ER-Fire.5, Alternate Shutdown for Battery Room "8" Fire;
. FRP-4.0, Fire Response Plan for Auxiliary Building Basement;
. FRP-5.0, Fire Response Plan for Auxiliary Building Intermediate Floor;
. FRP-18.0, Fire Response Plan for Battery Room "8"; and, o FRP-24.0, Fire Response Plan for EDG Room "A" and Cable Vault.
The team reviewed selected operator manual actions to verify whether they had been properly reviewed and approved and whether the actions could be implemented in accordance with plant procedures in the time necessary to support the safe shutdown method for each fire area. The team also reviewed the periodic testing of the alternative shutdown transfer and isolation capability, and instrumentation and control functions, to evaluate whether the tests were adequate to ensure the functionality of the alternative shutdown capability.
b. Findinqs
.1 Failure to Evaluate the lmpagt of Usinq the Volume Control Tpnk durinq Alternative
Shutdown lntroduction: The team identified a violation of very low safety significance (Green) of Ginna Operating License Condition 2.C.(3), "Fire Protection Program," for failure to evaluate the affects of allowing the volume control tank (VCT) to remain aligned to the "A" charging pump during alternative shutdown activities. The alternative shutdown procedures required manual alignment of the refuel water storage tank (RWST) to the charging pump. However, the VCT, normally pressurized with hydrogen (H2)gas for reactor coolant chemistry control, remained connected to the charging pump suction in parallelwith the RWST, which was vented to atmosphere. The potentialfor Hz gas to enter the charging pump was not analyzed to ensure the established safe shutdown flow path would not be adversely affected. This issue was determined to satisfy the criteria specified for the exercise of enforcement discretion for plants in transition to a fire protection program that meets the requirements of 10 CFR 50.48(c), "National Fire Protection Association Standard NFPA 805."
Description:
The Ginna safe shutdown analysis, documented in DA-EE-2000-066, "Appendix R Conformation Analysis," credited the "A" charging pump, aligned to the RWST, as providing the RCS makeup function. The VCT flow path to the charging pump was not protected from fire damage, and was not credited as a water source for RCS makeup in the safe shutdown analysis. ER-Fire.3, "Alternate Shutdown for Aux Building Basement/Mezzanine Fire," required operator manual actions (OMA) to align the RWST to the "A" charging pump and isolate sources of high-temperature water from the VCT, such as RCS letdown and reactor coolant pump (RCP) seal return water.
Those OMAs were required to be performed prior to locally starting the charging pump, were included in Constellation's Time CriticalAction Management Program, and were analyzed in DA-NS-2002-008, "Operator Action Time Requirement Evaluation." The team identified that the VCT outlet valve was not procedurally closed and remained open, aligned to the charging pump suction, in parallel with the flow path from the RWST. ln addition, the team also identified that the procedure steps to close the H2 gas supply to the VCT required re-entry into the auxiliary building basement and mezzanine (ABBM) fire area, did not take place until after charging pump flow was re-established, and were not included in Constellation's Time CriticalAction Management Program.
Based on available analysis and calculations, the team could not determine whether the VCT H2 gas could enter the pump's suction and gas bind the pump, resulting in a loss of the credited RCS makeup function. Therefore, the team concluded that Constellation had not adequately evaluated the effects of allowing the VCT to remain in parallel with the RWST during alternative shutdown for a fire in the ABBM.
Constellation performed an immediate detailed evaluation of this issue in ECP-12-000799, "Evaluation of Charging Pump Availability During Fire Scenarios."
Based on that evaluation, Constellation concluded that under the worst case fire scenario, the charging pump would entrain approximately 16 percent gas by volume for approximately the first 5 minutes, after which the gas entrainment would be reduced to approximately 2 percent. The calculation results were also reviewed by the pump vendor, who determined the charging pump could be expected to operate successfully under those circumstances. In addition, while this issue was being analyzed, Constellation implemented several interim compensatory measures to reduce the likelihood of fires in the ABBM, and installed a plant modification and procedure revision to ER-Fire.3 that included instructions to locally isolate the VCT outlet valve.
Constellation entered this issue into its corrective action program, as CR-2012-06410, for long term resolution.
The team reviewed Constellation's evaluation, interim compensatory measures, and procedure revisions, and concluded that the interim actions were adequate to address this fire protection program issue until a final evaluation is completed, in accordance with Constellation's NFPA 805 transition program.
Analvsis: Constellation's failure to ensure the RCS makeup function, credited in the safe shutdown analysis, would be maintained, and specifically to verify that the VCT and the H2 gas issue would not have an adverse effect on the reliability of the "A" charging pump was a performance deficiency. This finding was more than minor because it adversely affected the protection against external factors (i.e., fire) attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective of ensuring the availability and reliability of systems that respond to initiating events to prevent undesirable consequences. In addition, this issue was similar to NRC Inspection Manual Chapter (lMC) 0612, Appendix E, "Examples of Minor lssues," Example 3.k, which stated that an analysis to verify the adequacy of design contained incorrect assumptions. The example concluded that the issue was more than minor if the error resulted in a condition where there was a reasonable doubt on the operability of the component. For this issue, a knowledgeable engineer could not determine the adequacy of the safe shutdown analysis based on a review of existing analysis or calculations without performing additional complex analysis and preliminary calculations.
The team used IMC 0609, Significance Determination Process (SDP), Appendix F, 1, "Fire Protection SDP Phase 1 Worksheet," to determine the safety significance of this finding. Based upon the postulated ABBM fire scenario, Constellation determined by analysis that the charging pump would remain available for safe shutdown RCS makeup with both the VCT and RWST aligned and some limited VCT H2 gas entrainment. Accordingly, the team assigned a low degradation rating to this finding and the issue screened as very low safety significance (Green) per the Phase 1 evaluation risk criteria.
Cross-cutting aspects are not applicable to findings involving enforcement discretion.
Enforcement:
Ginna Operating License Condition 2.C.(3), "Fire Protection Program," in part, required Constellation to implement and maintain in effect all fire protection features described in licensee submittals referenced in and as approved or modified by the NRC's SER, dated February 1979, and subsequent supplements. ND-FPP, "Fire Protection Program," in part, stated that EPM-FPPR-ANL, "Fire Protection Program Report," was utilized to implement the fire protection program requirements approved by the NRC SER. EPM-FPPR-ANL Volume 3, Part lV, Section 4.2.1, in part, stated that for each safe shutdown system, the primary flow paths and operational characteristics that must be established to accomplish the desired safe shutdown performance goal were identified, as well as the components that established the primary safe shutdown flow path and/or system operation.
Contrary to the above, on September 21,2012, the NRC identified that Constellation did not identify the VCT flow path to the "A" charging pump was part of the RCS makeup flow path, and did not identify the operational characteristics that must be established to accomplish the desired safe shutdown performance goal of this flow path. Specifically, Constellation did not identify that the VCT remained connected to the charging pump (through the VCT outlet valve) in parallel with the RWST during alternative shutdown activities. Further, Constellation did not evaluate the impact of the VCT, which was normally pressurized with Hz gas, on the safe shutdown performance goal of that flow path. The violation was historical and occurred when Ginna completed its first safe shutdown analysis.
Constellation was in transition to NFPA 805 and, therefore, this NRC-identified violation was evaluated in accordance with the criteria established in Section 9.1 of the NRC's Enforcement Policy regarding Enforcement Discretion for Certain Fire Protection lssues (10 CFR Part 50.48). Because allthe criteria were met, the NRC exercised enforcement discretion for this issue.
Operator ManualActions to Restore Reactor Coolant Svstem Makeup Function not Feasible and Reliable Durinq Alternative Shutdown lntroduction: The team identified a violation of very low safety significance (Green) of Ginna Operating License Condition 2.C.(3), "Fire Protection Program," for failure to evaluate the feasibility and reliability of OMAs to restore the RCS makeup function during alternative shutdown for a fire in the ABBM. Several OMAs were required to be performed in the fire area to locally align the credited charging pump and a thorough evaluation of these OMAs as well as an evaluation to determine when the fire area could be reasonably reentered was not performed. This issue was determined to satisfy the criteria specified for the exercise of enforcement discretion for plants in transition to a FPP that meets the requirements of 10 CFR 50.48(c), "National Fire Protection Association Standard NFPA 805,"
Description:
While evaluating the alternative shutdown capability for a fire in the ABBM, the team questioned whether Constellation appropriately evaluated the feasibility and reliability of several OMAs to locally align the credited charging pump for the RCS makeup function of post-fire safe shutdown, The team walked down ER-Fire.3 and identified that an OMA to isolate RCP seal return to the VCT was performed at a location without any emergency light unit (ELU), During the walkdown, the team also identified that several additional OMAs were performed in the fire area before entering the charging pump room to locally operate the "A" charging pump. The charging pump room was a separate fire area within the ABBM.
The team reviewed several analyses to determine the timeline requirements to re-establish charging pump flow during an ABBM fire scenario, including:
.
DA-ME-2000-075, Pressurizer, VCT, and RWST Evaluations for Appendix R;
.
DA-NS-2002-008, Operator Action Time Requirement Evaluation; and,
.
DBCOR 2006-0057, Appendix R, Time CriticalTasks Validation for EPU.
The team identified that Constellation had determined by analysis that charging pump flow must be re-established within 23.9 minutes (i.e., approximately 24 minutes) to maintain pressurizer level in the indicating range consistent with the Appendix R performance goals for alternative shutdown systems. Additionally,lhe 24 minute timeline requirement had been reduced from 36.75 minutes (i.e., approximately 37 minutes) during the extended power uprate (EPU) modification in November 2006.
To support the timeline reduction in 2006, Constellation had performed two time validations: in one validation, 16 minutes was required to perform the OMAs; in the second validation, 17 minutes was required. Constellation concluded in DBCOR 2006-0057, "Appendix R Time Critical Tasks Validation for EPU," that operating crews could complete the required time critical actions within the required 24 minutes.
The team interviewed knowledgeable personnelabout the timeline validation performances and determined that Constellation did not adjust the simulated walkthroughs for realistic conditions that would be expected during an ABBM fire scenario. Realistic conditions that should have been considered included:
a Reduced visibility due to smoke; a Lighting only provided by ELUs; a Operators wearing a self contained breathing apparatus for the duration of the OMAs in the ABBM due to life safety concerns; a Potential high temperature conditions and heat stress; a Interference from fire brigade or fire suppression agents such as fire hoses and wet floors; and, Missing plastic valve labels or other challenges that may occur as the result of fire damage.
The team further determined that if 24 minutes were required to restore charging flow and, under the best conditions, 16 minutes were required to complete the OMAs within the ABBM, then an operator must enter the fire area, potentially alone and without turnout gear before the fire brigade would be expected to arrive on the scene, within about 8 minutes of fire initiation (24 - 16 = 8 minutes). The team concluded that Constellation had not adequately evaluated the reasonableness of entering a fire area within I minutes and had not adequately determined the reliability and feasibility of the OMAs to restore charging pump flow. Constellation entered this issue into its corrective action program, as CR-2012-06530 and CR-2012-006184, for long term resolution.
Constellation immediately staged a lantern at the RCP seal return isolation valve location, in lieu of an ELU, and performed a detailed assessment of the time required to re-establish charging pump flow, to evaluate the risk significance of a delay in this OMA.
As interim compensatory measures, Constellation promptly initiated a procedure change to ER-Fire.3 that provided operators with additional guidance on restoration of charging pump flow. The operators were also provided a shift briefing package (i.e., operator training) to understand the risk perspective and priority of charging pump restoration.
The team reviewed Constellation's interim compensatory measures and procedure revisions, and concluded that the interim actions were adequate to address the fire protection program issues until a final evaluation can be completed, in accordance with Constellation's NFPA 805 transition program.
The inspectors also reviewed Constellation's procedures for the review of fire protection program changes, because both issues (i.e., the lack of an ELU at the RCP seal return isolation valves, and the timeline validation for RCS makeup restoration) were the result of program changes to the fire protection program that had not been adequately reviewed. Constellation implemented and maintained two procedures that included instructions for FPP change reviews, A-202, "Staff Responsibilities for the Fire Protection Program," and EP-3-P-0132, "Fire Protection and Appendix R Conformance Verifications." EP-3-P-0132 was intended for reviewing station modifications, while A-202 was intended for all other plant changes, such as procedures, which were not specifically addressed by the modification process. Contrary to these procedure requirements, the new OMA (i.e., isolate RCP seal return) and the timeline requirement change (i.e., restore charging pump flow within 24 minutes) had not been reviewed in accordance with the checklist instructions provided within these two procedures.
Analvsis: Constellation's failure to adequately evaluate the FPP changes for OMAs that isolated RCP seal return and timeline requirements to restore charging pump flow that were reduced as a result of EPU implementation was a performance deficiency. This finding was more than minor because it adversely affected the protection against external factors (i.e., fire) attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective of ensuring the availability and reliability of systems that respond to initiating events to prevent undesirable consequences.
The team used IMC 0609, "Significance Determination Process (SDP)," Appendix F, 1, "Fire Protection SDP Phase 1 Worksheet," and Attachment 2, "Degradation Rating Guidance Specific to Various Fire Protection Program Elements," to determine the safety significance of this finding. A moderate degradation rating was assigned to this finding because the feasibility to perform specified OMAs was not apparent. Ginna was in transition to NFPA 805 and had recently completed a peer review of their fire probabilistic risk analysis (Fire PRA). Therefore, the team concluded that a more appropriate and accurate characterization of the risk significance of this issue would be obtained by using the Fire PRA to perform a Phase 3 evaluation.
Additionally, the ABBM fire scenario required the implementation of alternative safe shutdown procedures (i.e., control of several safe shutdown systems or components from outside the main control room) and the Phase 2 SDP did not explicitly address alternative safe shutdown fire scenarios.
For the Phase 3 evaluation, the Region I Senior Reactor Analyst (SRA) reviewed Constellation's risk assessment of this issue. Constellation used its recently completed Fire PRA to approximate the increase in risk associated with this issue. Constellation's evaluation assumed that operators would have 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to restore charging flow for the ABBM fire scenarios of interest. The 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> time limit was conservatively established based upon thermo-hydraulic analysis that determined there were approximately 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> before core uncovery, assuming RCS leakage of 364 gpm, for postulated failures of both RCP seals. The thermo-hydraulic analysis indicated that after 90 minutes (without operator intervention) the RCS water level would decrease to the elevation of the RCP seals, at which point steam flashing would occur and reduce the postulated leakage rate to within the capacity of one charging pump. Accordingly, the Fire PRA conservatively used two hours to complete the OMA. Unlike the Appendix R performance goals, to maintain reactor water level within the indicating range of the pressurizer, the success criteria for the Fire PRA model was to maintain RCS inventory sufficient to prevent core uncovery. For the fire scenarios of interest, this equated to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. Accordingly, a time delay (due to fire fighting activities) before an operator could reasonably access the ABBM, locally operate the charging pump, and perform related actions within the conservatively established 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> time period, would be insignificant with respect to the time available to ensure the core remained covered. The SRA's review determined that Constellation's risk assessment was reasonable and appropriately conservative for this NRC-identified issue.
Although Constellation's deterministic safe shutdown analysis relied upon completing this OMA within 24 minutes, a more detailed analysis in the Fire PRA demonstrated that allowing up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> would not result in any significant risk increase. Therefore, the SRA determined that this finding was of very low risk significance (Green).
Cross-cutting aspects are not applicable to findings involving enforcement discretion.
Enforcement.
Ginna Operating License Condition 2.C.(3), "Fire Protection Program," in part, required Constellation to implement and maintain in effect all fire protection features described in licensee submittals referenced in and as approved or modified by the NRC's SER dated February 1979, and subsequent supplements. ln addition, the license condition allowed Constellation to may make changes to the approved fire protection program without prior NRC approval only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.
ND-FPP, "Fire Protection Program," in part, stated that A-2A2 and other Ginna Station Procedures were utilized to implement fire protection program requirements approved by the NRC SER.
EP-3-P-01 32, "Fire Protection and Appendix R Conformance Verifications," Section 1.1.2, in part, stated that this procedure ensured applicable Appendix R analyses were reviewed for plant modifications. EP-3-P-0132, Attachment 2, "Appendix R/Fire Protection Conformance Verification Checklist," Section C, required that the basis for acceptability and the conclusion that the change did not adversely impact the ability to achieve and maintain safe shutdown shall be documented.
ln addition, A-202, "Staff Responsibilities for the Fire Protection Program," Section 3.1.2, "lnstructions," stated that the license condition allowed changes to the approved fire protection program without prior NRC approval only if those changes did not adversely affect the ability to achieve and maintain safe shutdown. In addition, Section 3.1.2 required that 4-202 Attachment A, "Fire Protection Program and Appendix R Conformance Review Screen," shall be completed for all proposed changes that
- (1) were not addressed by the modification process, and
- (2) changed fire program procedures, to determine if further review was required and to document the acceptability of the proposed changes.
Contrary to the above, Constellation made changes to the approved fire protection program, through a modification (in 2006) and a procedure change (in 2Q12), without first verifying that those changes did not require further review and did not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.
Specifically, on October 31, 2006, Constellation implemented an EPU modification that included revising DA-N5-2002-008, "Operator Action Time Requirement Evaluation," to reduce the timeline within which the "A" charging pump flow must be re-established.
However, Constellation did not perform the required verifications and, as a result, did not evaluate the reasonableness of the reduced timeline to determine whether the change adversely impacted the ability to achieve and maintain safe shutdown. Specifically, on April 20, 2010, Constellation revised ER-Flre.3, "Alternate Shutdown for Aux Building Basement I Mezzanine Fire," to include operator manual actions within that fire area to isolate RCP seal return flow to the VCT. However, Constellation did not perform the required screen and, as a result, did not determine whether further review was required.
Constellation was in transition to NFPA 805 and, therefore, this NRC-identified violation was evaluated in accordance with the criteria established in Section 9.1 of the NRC's Enforcement Policy regarding Enforcement Discretion for Certain Fire Protection lssues (10 CFR Part 50.48). Because all the criteria were met, the NRC exercised enforcement discretion for this issue.
.06 Circuit Analvsis
Inspection Scope The team reviewed Constellation's post-fire safe shutdown analysis for the selected fire areas to determine whether the analysis identified both required and associated electrical circuits and cables for the systems and components necessary to achieve and maintain safe shutdown. The team reviewed electrical schematics and cable routing data for power, control, and instrument cables associated with selected components.
Specifically, the team evaluated the selected circuits and cables to determine whether they were
- (a) adequately protected from potential fire damage, or
- (b) analyzed to show that fire-induced faults (e,g., hot shorts, open circuits, and shorts to ground) would not prevent safe shutdown, or
- (c) analyzed to show that potential damage could be mitigated with approved operator manual actions, in order to verify whether fire-induced faults could adversely impact safe shutdown capabilities. The team's evaluations considered credible fire scenarios, cable insulation attributes, cable failure modes, cable routing, and common power supply or electrical bus configurations.
In addition, the team reviewed cable raceway drawings and cable routing databases for a sample of components required for post-fire safe shutdown to determine whether those cables were routed as described in the safe shutdown analysis. The team also reviewed equipment important to safe shutdown, but not part of the success path, to assess whether Constellation's safe shutdown methodologies were appropriate, conformed to design and licensing basis requirements, and appropriately considered the guidance in NRC Regulatory Guide 1
.189 , "Fire Protection for Nuclear Power Plants,"
Revision 2.
Cable failure modes were reviewed for the following components:
.
"A" Service Water Pump (PSW01A)
.
"A" Charging Pump (PCH01A)
.
"A" Component Cooling Water Pump (PAC02A)
.
"A" Residual Heat Removal Pump (PAC01A)o "A" Steam Generator Atmospheric Relief Valve (AOV-341 1)
.
Pressurizer Power Operated Relief Valve (PCV-430)
.
Pressurizer Power Operated Relief Valve (PCV-431C)
The team reviewed a sample of circuit breaker and fuse over-current protection coordination studies to determine whether equipment, needed for postfire safe shutdown activities, could be adversely affected due to a lack of coordination that could result in a common power supply or common electrical bus concern. The team also evaluated whether coordination studies appropriately considered multiple faults due to fire. In addition, the team reviewed a sample of circuit breaker maintenance records, for components required for safe shutdown, to determine whether the breakers were properly maintained.
The team assessed the transfer of controlfrom the control room to the alternative shutdown locations to determine whether it would be affected by fire-induced circuit faults (e.g., by the provision of separate fuses and power supplies for alternative shutdown control circuits).
b. Findinqs No findings were identified.
.07 Communications
a. Inspection Scope
The team reviewed safe shutdown procedures, the safe shutdown analysis, and associated documents to verify whether an adequate method of communications would be available to plant operators following a fire. Specifically, the team evaluated whether plant telephones, page systems, and portable radios would be available for use and were properly maintained. During this review, the team considered the effects of ambient noise levels, clarity of reception, reliability, and coverage patterns. The team inspected selected emergency storage lockers to independently verify whether portable communication equipment was available for the fire brigade and plant operators. In addition, the team evaluated whether radio or phone repeaters, transmitters, and power supplies would be reasonably unaffected by a fire.
Findintrs No findings were identified.
.08 Emerqencv Liqhtinq
a. Inspection Scope
The team walked down the emergency lights in the selected fire areas to independently evaluate the placement and coverage areas of the lights. The team assessed whether the lights provided adequate illumination on local equipment and instrumentation required for post-fire safe shutdown, to ensure local operations could be reliably performed under expected post-fire conditions. Emergency light placement was also evaluated to determine adequate illumination of local area access and egress pathways.
The team verified whether the emergency light batteries were rated for at least an 8-hour capacity. Preventive maintenanCe procedures, the vendor manual, completed surveillance tests, and battery replacement practices were also reviewed to evaluate whether the emergency lighting had been maintained in a manner that would ensure reliable operation.
b. Findinqs No findings were identified.
.09 Cold Shutdqwn Repairs
a. Inspection Scope
The team reviewed Constellation's procedure instructions to repair components which might be damaged by fire and were required to achieve post-fire cold shutdown. The team evaluated selected cold shutdown repairs to determine whether they could be achieved within the time frames assumed in the design and licensing bases. In addition, the team verified whether the necessary repair equipment, tools, and materials (e.9.,
pre-cut cables with prepared attachment lugs) were available and accessible on site.
b. Findinqs No findings were identified.
.10 Compensatorv Measures
Inspection Scope The team verified whether compensatory measures were in place for out-of-service, degraded, or inoperable fire protection and post-fire safe shutdown equipment, systems, or features (e,g., detection and suppression systems and equipment, passive fire barriers, pumps, valves, or electrical devices providing safe shutdown functions or capabilities). The team evaluated whether the short term compensatory measures adequately compensated for the degraded function or feature until appropriate corrective action could be taken and whether Constellation was effective in returning the equipment to service in a reasonable period of time.
The team noted that for the selected fire areas, which were designated as 10 CFR Part 50 Appendix R, Section lll.G.2 areas, there were no compensatory measures in the form of operator manual actions.
b. Findinos No findings were identified.
.11 Review and Documentation of Fire Protection Proqram Chanqes
a. Inspection ScoQe The team reviewed recent changes to the approved fire protection program to assess whether those changes had an adverse effect on the ability to safely shutdown, b. Findinqs No findings were identified.
.12 Control of Transient Combustibles and lqnition Sources
a. Inspection Scope
The team reviewed Constellation's procedures and programs for the control of ignition sources and transient combustibles to assess their effectiveness in preventing fires and in controlling combustible loading within limits established in the FHA. A sample of hot work and transient combustible control permits were reviewed to assess the adequacy of Constellation's fire protection program administrative controls. The team performed plant walkdowns to independently verify whether transient combustibles and ignition sources were being properly controlled in accordance with administrative controls.
b. Findinqs No findings were identified.
.13 Larqe Fires and Explosions Mitiqation Strateqies
a. Inspection Scope
The team reviewed selected mitigation strategies intended to maintain or restore core decay heat removal and spent fuel pool cooling capabilities under the circumstances associated with loss of large areas of the plant due to large fires or explosions. The team assessed whether Constellation continued to meet the requirements of license Condition 2.C.(8) and 10 CFR 50.54(hhx2). The team reviewed three mitigation strategies:
.
lnternal and External Spent Fuel Pool Makeup and Spray r Turbine-Driven Auxiliary Feedwater Pump Manual Operation
.
Steam Generator Depressurization and Makeup Using the Portable Pump The team's review included: a detailed assessment of the procedural guidance; a walk down of the strategies with trained operators to assess the feasibility of the strategies and operator familiarity; maintenance and surveillance testing of all designated strategy equipment; and an independent inventory check of all strategy equipment to ensure the appropriateness of equipment storage and availability. The team also evaluated the adequacy of corrective actions associated with issues identified during previous inspections as well as reviewed a recent self-assessment in this area.
b. Findinos No findings were identified.
OTHER ACTIVITIES
4OA2 ldentification and Resolution of Problems (lP 71152)
a. Inspection Scope
The team reviewed a sample of CRs associated with the fire protection program, post-fire safe shutdown issues, and mitigation strategy issues to determine whether Constellation was appropriately identifying, characterizing, and correcting problems associated with these areas and whether the planned or completed corrective actions were appropriate. The CRs reviewed are listed in the attachment' b. Findinqs No findings were identified.
4OAO Meetinqs. includinq Exit The team presented the inspection results to Mr. Joseph Pacher, Site Vice President, and other members of Constellation's staff on September 28,2012. The team verified that this report does not contain proprietary information'
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTAGT
Licensee Personnel
- K. Charland, Licensing Engineer
- M. Edelstein, Fire Marshal
- S. Kimbrough, PRA Engineer
- J. Jackson, Supervisor, Licensing
- C. Junot, Fire Protection Specialist
- D. Lovegren, Electrical Design Engineer
- K. Masker, Operations Procedure Writer
- M. McGraw, Fire Protection System Engineer
- T. Miller, Electrical Design Engineer
- P. Schipp, Supervisor, Electrical/ l&C Design Engineering
B, Weaver, Supervisor, BOP Engineering
NRC Personnel
- N. Perry, Senior Resident Inspector - Ginna
- D. Dodson, Resident Inspector - Ginna
- D. Frumkin, Fire Protection Branch, Risk Assessment Division, Nuclear Reactor Regulation
(NRR)
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
None.
LIST OF DOCUMENTS REVIEWED
Fire Protection Licensinq and Desion Basis Documents
DA-EE-2000-066, Appendix R Conformation Analysis (safe shutdown analysis), Rev. 2
EPM-FPPR ANL, Fire Protection Program Report Volumes 1, 2, & 3, Rev. 8
Letter, RG&E to NRC, Appendix R, Alternative Shutdown System (accession no. 8401250104),
dated 1116184
Letter, RG&E to NRC, Fire IPEEE (M1080170020), dated 6/30/98
Letter, RG&E to NRC, Fire Protection (accession no. 4006003751), dated 2124/77
ND-FPP, Fire Protection Program (FPP), Rev 14
NRC Branch Technical Position (BTP) APCSB 9.5-1 and Appendix A, Guidelines for Fire
Protection for Nuclear Power Plants
NRC Safety Evaluation Report (SER), Amendment No. 24 to Ginna Operating License Adding
License Condition Relating to the Completion of Facility Modifications for Fire Protection
(accession no. 79031 40202), dated 21 1 4/79
NRC SER Supplement No. 1, Fire Protection (accession no. 8103090712), dated 12117180
NRC SER Supplement No. 2, Fire Protection (accession no. 8102270116), dated 216181
NRC SER Supplement No. 3, Fire Protection (accession no. 8107150433), dated 6122181
NRC SER, Appendix R ltems lll.G.3. and lll.
- L. (accession no. 8503050432), dated 2127185
NRC SER, Exemptions to lll.
- G. of Appendix R (M1010540388), dated 3121185
UFSAR Section 9.5.1, Fire Protection Systems, Rev' 23
Calculations. Analvsis. and Enqineerinq Evaluations
109682-M-012, Appendix R Steam Generator Water Solid Cooldown Analysis with RELAP5 for
EPU, Rev.0
1-DC-787-0428-11, Fixed Fire Suppression Systems Modifications (EWR-1833), Rev. 2
1-DC-787-0428-22, Fixed Fire Suppression Systems Modifications (EWR-1833), Rev. 0
2-5009845-00, Ginna Safe Shutdown RELAP5 Analysis, Rev' 0
51-9089546-00, Nuclear safety capability Assessment, dated 212112
,4-601.10, Time CriticalAction Management Program, Rev' 0
DA-EE-2000-066, Appendix R Conformance Analysis, Rev. 2
DA-EE-93-104-07,480V Coordination and Circuit Protection Study, Rev. 7
DA-EE-g3-107-O7,4kV Overcurrent Relays Coordination & Circuit Protection Study, Rev. 5
DA-EE-96-005-07, Motor Control Center Coordination Analysis, Rev. 14
DA-EE-99-066, DC System Fuse Coordination, Rev' 2
DA-ME-2000-001, City Water Yard Loop to EDG Cooling, Rev. 5
DA-ME-2000-040, City Water Yard Loop Cross-Tie to Fire Yard Loop, Rev. 3
DA-ME-2000-062, lmpact of Fire on Service Water Piping in EDG1B, Rev. 0
DA-ME-2000-075, Pressurizer, VCT, and RWST Evaluations Rev. 2
DA-ME-2001-031, Fire System Flow & Pressure Requirements, Rev. 2
DA-ME-94-004, Fire Hose Reel Design Analysis, Rev' 0
DA-ME-94-118-02, PENQ-O2 Caulk Seal Qualification, Rev' 0
DA-ME-94-118-10, PENQ-10 Cable Tray Seal Qualification, Rev. 0
DA-ME-94- 118-11, PENQ-1 1 Pipe/ConduiUsleeve Seal Qualification, Rev. 0
DA-ME-96-070, Fire Water Sprinkler Hydraulic Calculations, Rev. 1
DA-NS-2002-008, Operator Action Time Requirement Evaluation, Rev. 5
DBCOR 2006-0057, Appendix R Time Critical Tasks Validation for EPU, dated 10/31/06
DBCOR 2008-0071, Review Fire Area Assessment - Fire Area ABBM, dated 811108
DBCOR 2008-0079, Review Fire Area Assessment - Fire Area EDG1A, dated 811108
ECP-12-000799, Evaluation of Charging Pump Availability During Fire Scenarios, Rev. 0
ER-SC.2, High Water (Flood) Plan, Rev. I
EWR-1833 Section 10, Sectionalizing Valves on Existing Fire Piping, Rev. 0
JN-4, Sizing N2 Supply Requirements, Rev. 0
SC-3.17, Auxiliary Bldg Flood Barrier Installation/Removal/lnspection, Rev. 2
Drawinqs and Wirinq Diaorams
03021-1055, Permanent Caulk Seal Details, Rev. 0
03021-1063, Cable Tray Penetration Seal Details, Rev. 0
03021-1064, Pipe/Conduit/Sleeve Fire Penetration Seal Details, Rev' 0
$A21-1066, Non-rated Fire Penetration Seal Details, Rev' 0
21488-0100 Sh. 4, Fire, Smoke, & Pressure Barriers, Rev. 13
21488-0102 Sh. 1, Battery Room Penetration Locations, Rev. 5
21488-0102 Sh. 2, Battery Room Penetration Locations, Rev. 10
21488-011 1 Sh. 4, 1B EDG Penetration Locations, Rev. 5
21488-0201 Sh. 1&3, Hemyc FireWrap in Battery Room, Rev. 1
21946-0071A Sh. 1,480V Bus 14 Charging Pump A Control Schematic, Rev.5
21946-0071A Sh. 2,480V Bus 14 Charging Pump A Control Schematic, Rev. 3
21946-0072A Sh. 1, 480V Bus 14 Component Cooling Water Pump Control Schematic, Rev. 6
21946-0072A Sh. 2,480V Bus 14 Component Cooling Water Pump Control Schematic, Rev. 1
21946-00784, 480V Bus 14 Residual Heat Removal Pump Control Schematic, Rev. 5
21946-0081A Sh. 1, 480V Bus 18 Service Water Pump A Control Schematic, Ref 4
21946-0081A Sh. 2,480V Bus 18 Service Water Pump A Control Schematic, Ref 4
21946-0730 Sh. 1, AOV-341 1, S/G Atmospheric Relief Valve Control Schematic, Rev. 4
21946-0730 Sh. 2, AOV-3411, S/G A Atmospheric Relief Valve Control Schematic, Rev. 2
21946-0754 Sh. 1&2, Pressurizer Power Operated Relief Valve Control Schematic, Rev. 1
21946-0755 Sh. 1&2, Pressurizer Power Operated Relief Valve Control Schematic, Rev. 1
330'13-0710A Sh. 1, EDG Elementary Diagram, Rev' 11
33013-1537,18 EDG Vault Fire Barrier, Rev. 4
33013-1736 Sh. 1, EDG Control Schematic, Rev. 15
33013-1736 Sh.2, EDG Control Schematic, Rev. 17
33013-2543, Auxiliary Bldg Basement Fire Response Plan (hazard barrier dwg), Rev. 3
33013-2544, Turbine Bldg Basement Fire Response Plan (hazard barrier dwg), Rev. 10
39013-2546, Auxiliary Bldg Intermediate Floor Fire Response Plan (hazard barrier dwg), Rev. 4
33013-2552, Auxiliary Bldg Operating Floor Fire Response Plan (hazard barrier dwg), Rev. 8
33013-2555, TSC Fire Response Plan (hazard barrier dwg), Rev' 8
33013-2559, Control Bldg Basement Fire Response Plan (hazard barrierdwg), Rev. 11
33013-2560, Transformer Yard Fire Response Plan (hazard barrier dwg), Rev, 4
33013-2567, Control Bldg Sections Fire Response Plan (hazard barrier dwg), Rev. 3
33013-2568, Auxiliary Bldg Sections Fire Response Plan (hazard barrier dwg), Rev. 1
33013-2571, Screen House Fire Response Plan (hazard barrier dwg), Rev. 6
21A-P Seal Details from Fire Protection lmpairment Tracking System, dated 9113112
BB-1-P Seal Details from Fire Protection lmpairment Tracking System, dated 9113112
BB-52-P Seal Details from Fire Protection lmpairment Tracking System, dated 9113112
BB-56-P Seal Details from Fire Protection lmpairment Tracking System, dated 9113112
C206886w, Motor Driven Fire Pump Certified Test Curve, dated 4126102
C206888w, Engine Driven Fire Pump Certified Test Curve, dated 4126102
D-201-016, EDG ElectricalVaults, Rev. 6
D-215-161, EDG Power Duct Run , Rev. 7
l-305A-P Seal Details from Fire Protection lmpairment Tracking System, dated 9113112
PACAD-2103, Auxiliary Bldg Basement Floor Arrangement, Elev. 235 ft., Rev. 0
Pioinq and lnstrumentation Diaqrams
33013-1265, Sh. 1, Chemical Volume Control System Charging (CVCS)' 12
33013-1265, Sh.2, ChemicalVolume Control System Charging (CVCS)' 24
33013-1606 Sh. 1, Fire Protection System Yard Loop P&lD, Rev.2
33013-1989, Fire Protection System P&lD, Rev. 25
33013-1990 Sh. 1, Fire Protection System P&lD, Rev' 15
33013-1990 Sh. 2, Fire Protection System P&lD, Rev. 10
33013-1991, Fire Protection System P&lD, Rev. 19
33013-1992, Fire Protection System P&lD, Rev. 11
33013-1993, Fire Protection System P&lD, Rev. 10
Larqe Fires and Exolosions Mitiqation Strateoies Documents
ER-AFW.3, Alternate Standby Auxiliary Feedwater, Rev. 3
ER-CNMT.1, Flooding Containment, Rev. 0
ER-EDMG.0, Emergency Damage Mitigation Guidelines, Rev.
ER-RWST.1, Alternate RWST Makeup, Rev. 1
ER-SFP.2, Diverse SFP Makeup and Spray, Rev' 2
sc-3.15.15, Emergency Fire Equipment Inventory and Inspection, Rev. 92
Fire Protection Evaluations of Modifications and Desion Chanoes
2, Evaluation of Compensatory Measures for Degraded Hemyc, Rev. 21
ECP-12-000305, Appendix R Radio Communications Upgrade, Rev' 1
Qualitv Assurance Audits and Self Assessments
QA-201 2-0052 5.57.1, Fire Protection Program lnspection Readiness, dated 7131112
SA-2009-000049, Fire Protection Program Focused Self Assessment, dated 7130109
SA-2012-000153, Fire Protection Program Focused Self Assessment, dated 7119112
Svstem Health Reports
20VAC Instrument Power System, 1st Quarter 2012
20VAC Instrument Power System, 2nd Quarter 2012
25VDC Electrical System, 1st Quarter 2012
25VDC Electrical System, 2nd Quarter 2Q12
4160VAC Electrical System, 1st Quarter 2012
4160VAC Electrical System, 2nd Quarter 2012
Attachmenl
480VAC Electrical System, 1st Quarter 2012
480VAC Electrical System, 2nd Quarter 2012
Diesel Generator Emergency Power System, 1st Quarter 2012
Diesel Generator Emergency Power System, 2nd Quarter 2012
Emergency Lighting System, 1st Quarter 2012
Emergency Lighting System, 2nd Quarter 2012
Fire Protection Program, 1st Quarter 2012
Fire Protection Program, 4th Quarter 2011
Fire Protection System, 1st Quarter 2012
Fire Protection System, 4th Quarter 2011
Procedures
2.12,Fire Watch Training, Rev. 16
A-2Q2, Staff Responsibilities for the Fire Protection Program, Rev' 28
A-905, Open Flame, Welding and Grinding Permit (Hot Work Permit), Rev. 42
CH-190, Diesel Fuel OilTesting Program, Rev. 4
CH-240, Sampling, Handling, & Evaluation of Fuel Oil Storage tanks, Rev. 0
EP-3-P-0132, Fire Protection and Appendix R Conformance Verifications, Rev. 6 & 7
ER-Fire.S, Alternate Shutdown for Battery Room B Fire, Rev. 2
FPS-1, Fire Barrier Control Procedure, Rev. 11
FPS-16, Butk Storage of Combustible Materials and Transient Fire Loads, Rev. 15
FPS-2, Fire Barrier Penetration Seal Program, Rev. 7
FPS-3, Periodic Inspection of Fire Barrier Penetration Seals, Rev' 1
FPS-7, Velocity Flush of the Fire Water System, Rev. 15
GME-00-99-ACFUSES, Replacement or Inspection of Ac Fuses, Rev. 01
GME-00-99-DCFUSES, Replacement or Inspection of DC Fuses, Rev. 02
GME-S0-02-D825, Westinghouse 480V Air Circuit Breaker, Type DB-25, Maintenance, Rev. 21
GME-SO-02-D850, Westinghouse 480V AIR Circuit Breaker, Type DB-50, Maintenance, Rev. 23
GME-S0-02-D875, Westinghouse 480V Air Circuit Breaker, Type DB-75, Maintenance, Rev. 25
GME-50-02-DBSETUP, Westinghouse DB Breaker Setup, Rev. 9
M-11.30.1, Motor Driven or Diesel Driven Fire Pump Minor Maintenance, Rev. 24
M-11.30.2, Diesel Fire Pump Right Angle Drive Minor Maintenance, Rev' 19
M-32.6, Molded Case Circuit Breaker Bench Test Trip Test, Rev' 12
PRI-07-02-BUS11A, Protective Relay Calibration. 4kV Bus 11A Relaying, Rev. 7
PRI-07-02-BUS1 18, Protective Relay Calibration, 4kV Bus 1 1B Relaying, Rev. 8
PRI-07-02-BUS124, Protective Relay Calibration, 4kV Bus 12A Relaying, Rev. 3
PRI-07-02-BUS128, Protective Relay Calibration, 4kV Bus 128 Relaying, Rev. 4
SC-3.4.1, Fire Brigade Captain and Control Room Personnel Responsibilities, Rev. 3
STP-O-12.8.1, DC Diesel Generator Load Test, Rev. 1
STP-O-12.9,DC Diesel GeneratorTest, Rev. 1
STP-O-13, Fire Pump Operation and System Alignment, Rev' 1
STP-O-13.1 , Annual Fire Pump Insurance Surveillance Test, Rev. 3
STP-O-13.2, Diesel Fire Pump Standard Protection Test, Rev' 0
STP-O-13.4, Diesel Driven Portable Pump Test, Rev' 2
STP-O-1 3.4.1, BSb Pump Annual Flow Test, Rev. 1
STP-O-13.4.14, Deluge Valve System Test, Auxiliary Charcoal Filter, Rev. 0
Operations Procedures
ATT-12.0, Attachment N2 PORVS, Rev. 6
ER-D/G.2, Alternate Cooling for D/GS, Rev. 19
ER-Fire.0, Control Room Response to Fire Alarms and Reports, Rev. 9
ER-Fire.3, Alternate Shutdown for Aux Building BasemenUMezzanine Fire, Rev. 32
ER-Fire.S, Alternate Shutdown for Battery Room B Fire, Rev. 24
O-20, Operations DC Fuse Replacement, Rev. 0
0-6.1, Auxiliary Operator Rounds and Log Sheets, Rev. 46
PCR 2003-0028, Required Appendix R Spare Air Supply Volume, Rev. 0
PCR 2004-0009, Ginna Extended Power Uprate Project, Rev. 0
PCR 2005-0028, EPU NSSS Setpoint, Scaling and Instrumentation Changes, Rev. 0
PCR 2005-0041, Consolidate Local Controls for Charging Pump A for EPU, Rev. 0
PCR 2011-5468 to ER-D/G.1, Restoring Diesel Generators, Rev' 16
PCR 2012-4881 to ER-FIRE.3, Alternate Shutdown for Auxiliary Bldg Basement Fire, Rev. 31
SC-3.16.2.1, Fire Control Panel Operating Instruction, Rev' 5
Operator Safe Shutdown Traininq
Continuing Training Attendance Sheets for Lesson Plan RER22C, dated 4116110 to 5121110
JPM J004.009, Take Local Manual Control of Charging Pump, Rev. 3
JPM JR064.004, Start "A" EDG Locally per ER-Fire.1, Rev. 0
Licensed Operator Initial Training Attendance Sheets for JPM JR 064.004, dated
20112 and 213112
RER22C, Appendix R - Alternative Shutdown, Rev. 9
Fire Fiqhtinq Strateqies (i.e., Pre-Fire Plans)
FRP-4.0, Fire Response Plan for Auxiliary Building Basement, Rev. 8
FRP-5.0, Fire Response Plan for Auxiliary Building Intermediate Floor, Rev. 9
FRP-6.0, Fire Response Plan for Auxiliary Bldg Operating Floor, Rev' 7
FRP-15.0, Fire Response Plan for Cable Tunnel, Rev' 7
FRP-18.0, Fire Response Plan for Battery Room B, Rev. 6
FRP-24.0, Fire Response Plan for EDG Room A and Cable Vault, Rev' 5
Fire Briqade Traininq
A-103.9, Fire Brigade Training, Rev. 3
LP FFB31C, Fire Brigade Responsibilities, Rev. 9
LP FFB36C, Fire Brigade Response, Rev. 3
Fire Briqade Drills and Critiques
Fire Drill Scenario 2007-002, performed 1113111
Fire Drill Scenario 2008-008, performed 1119111
Fire Drill Scenario 2011-003, performed 1121111
Fire Drill Scenario 2011-002, performed 2110111
Fire Drill Scenario 2011-006, performed 411111, 4112111,6116111, and 6126111
Fire Drill Scenario 2008-010, performed 7 18111
Fire Drill Scenario 2011-001, performed 7129111
Fire Drill Scenario 2006-009, performed 812111
Fire Drill Scenario 2009-003, performed 814111
Fire Drill Scenario 2008-015, performed 9126111
Fire Drill Scenario 2009-013, performed 1015111
Fire Drill Scenario 2011-010, performed 1016111
Fire Drill Scenario 2011-020, performed 1116111
Fire Drill Scenario 2009-002, performed 1116111
Fire Drill Scenario 2012-019, performed 9111112
Transient Combustible Permits and Evaluations
2012-003, 2012-004, 2012-005, 2012-006, and 2012-008
Hot Work and lonition Source Permits
Hot Work Permits12-127, 12-130,12-131, 12-133,12-134, 12-153, and 12-157
Completed Tests and Surveillances
FPS-2.1, Appendix R Fire Barrier Verification, performed 10129107
FPS-?.2, Non-Appendix R Fire Barrier Verification, performed 10122110
FPS-3, Fire Barrier Penetration Seals Inspection, performed 5113111
FPS-7, Fire Water System Velocity Flush, performed 4120109 and 5127112
M-103, Fire Damper Maintenance and lnspection, performed 1117112
PM P103343, Radio Communication System, performed 4114107
PM P203302, Radio Communication System, performed 7 118109
PM P900027, Radio Communication System, performed 4l28l10
PT-13.26, Fire Damper Testing, performed 12119105
STp-O-13, Fire Pump Operation and System Alignment, performed 615112 and 718112
STP-O-1 3.1 , Annual Fire Pump insurance Surveillance Test, performed 12129110 and 12128111
STP-O-1 3.11.19, Smoke Detector Testing, Auxiliary Bldg Basement, performed 4124110
STP-O-13.2, Diesel Fire Pump Standard Protection Test, performed 1213Q111
STP-O-13.22.1, Fire System Flow Alarm Check, performed 4116111
Condition Reports (* denotes NRC identified during this inspection)
cR-2009-0003 cR-2009-2190 cR-2009-5582 cR-2009-8727
cR-2009-0422 cR-2009-2305 cR-2009-6284 cR-2009-8933
cR-2009-0590 cR-2009-2331 cR-2009-7409 cR-2009-8966
cR-2009-0819 cR-2009-3226 cR-2009-7765 cR-2009-9034
cR-2009-0880 cR-2009-3397 cR-2009-8124 cR-2009-9052
cR-2009-0881 cR-2009-3877 cR-2009-8217 cR-2009-9342
cR-2009-1260 cR-2009-4110 cR-2009-8340 cR-2009-9343
cR-2009-1476 cR-2009-4445 cR-2009-8510 cR-2009-9537
cR-2009-2052 cR-2009-5459 cR,2009-8560 cR-2010-0039
cR-2009-2099 cR-2009-5507 cR-2009-8605 cR-2010-0040
cR-2010-0294 cR-2010-7620 cR-2012-3299 cR-2012-6159.
cR-2010-2344 cR-2011-2140 cR-2012-3511 cR-2012-6161*
cR-2010-3081 cR-2011-3484 cR-2012-3607 cR-2012-6173"
cR-2010-3465 cR-2011-4605 cR-2012-4281 cR-2012-6184.
cR-2010-4262 cR-2011-4985 cR-2012-4324 cR-2012-6192*
cR-2010-4290 cR-2011-5120 cR-2012-5024 cR-2012-6196*
cR-2010-4302 cR-2011-5708 cR-2012-5035 cR-2012-6222*
cR-2010-4475 cR-2011-5716 cR-2012-5254 cR-2012-6223.
cR-2010-4592 cR-2011-6390 cR-2012-5255 cR-2012-6346.
cR-2010-6084 cR-2011-6392 cR-2012-5256 cR-2012-6390
cR-2010-6336 cR-201205261 cR-2012-5258 cR-2012-6410-
cR-2010-6337 cR-2012-0649 cR-2012-5259 cR-2012-6440"
cR-2010-7219 cR-2012-0838 cR-2012-5993. cR-2012-6501.
cR-2010-7356 cR-2012-2413 cR-2012-6004" cR-2012-6530*
cR-2010-7395 cR-2012-3286 cR-2012-6144.
Work Orders
20504259 c90818690 c91246083 c91714786
c20600793 c90989518 c91268328 c91752548
c20900877 c90995122 c91268496 Rl 31 3946
c20901227 c91212076 c91 5381 71 R1313950
c90678575 c91212107 c91 539682 R1341339
c90732763 c91245345 c91640027 R1341340
Vendor Manuals
WD-C1436-4702, Emergency Lighting Units, Rev. 0
Industrv Standards
NFPA 13-1985, lnstallation of Sprinkler Systems
NFPA 15-1985, Water Spray Fixed Systems
NFPA 20-1983, Centrifugal Fire Pumps
Miscellaneous Documents
2.12 Attachment 3, Control of LCO for Fire Suppression, Detection and Fire Barriers
(lmpairment Log), dated 9110112
A-54.7, Hemyc Wrap (Operator Rounds)
Certificate of Analysis, Diesel Fuel Oil Sample, dated 2123112
Fire Tank Booster Pump Trend Point Plot, from 8/15112to 8129112
Letter, LS05-81-09-018, NRC to RG&E, Systematic Evaluation Program Topic lll-5.8, Pipe
Break Outside Containment (M18109140113), dated 914181
Margin lssue 2950, Fire Pumps Do Not Meet NFPA 20 Requirements, dated 9111112
NRC Enforcement Policy (ML12132A394), dated 617112
NRC Information Notice (lN) 2009-02, Biodiesel Fuel Oil Adverse lmpact to Diesel Engine
Performance, dated 2l23l}g
NRC lN 2009-29, Potential Failure of Fire Water Supply Pumps to Automatically Start due to
a Fire, dated 11124109
NRC Regulatory Guide 1 .189, Fire Protection for Nuclear Power Plants, Rev. 2
Purchase Order No. 6614401, Diesel Fuel OilTesting, dated 211112
LIST OF ACRONYMS
ABBM Auxiliary Building Basement and Mezzanine
ADAMS Agencyruide Documents Access and Management System
APCSB INRCI Auxiliary and Power Conversion Systems Branch
BTP [NRC] Branch Technical Position
CCW Component Cooling Water
CDF Core Damage FrequencY
CFR Code of Federal Regulations
Constellation Constellation Energy Nuclear Group
CR Condition Report
EDG Emergency Diesel Generator
Elev. Elevation
ELU Emergency Light Unit
EPU Extended Power UPrate
FHA Fire Hazards AnalYsis
FPPR Fire Protection Program Report
ft Foot
Ginna R.E. Ginna Nuclear Power Plant
H2 Hydrogen
IMC [NRC] Inspection Manual Chapter
lN [NRC] lnformation Notice
lP [NRC] lnspection Procedure
IPEEE Individual Plant Examination of External Events
lR [NRC] Inspection RePort
Nz Nitrogen
NEI Nuclear Energy Institute
NFPA National Fire Protection Association
NRC Nuclear Regulatory Commission
NRR [NRC] Nuclear Reactor Regulation
OMA Operator ManualAction
PARS Publicly Available Records System
PCR Procedure Change request
P&lD Piping and lnstrumentation Drawing
PRA Probabilistic Risk Assessment
RCP Reactor Coolant PumP
RG [NRC] Regulatory Guide
RG&E Rochester Gas and Electric [previous licensee]
RWST RefuelWater Storage Tank
SDP INRC] Significance Determination Process
SER [NRC] Safety Evaluation Report
SFP Spent Fuel Pool
SRA Senior Reactor Analyst
SSC Structures, Systems and Components
UFSAR Updated Final Safety Analysis Report
VAC Volts Alternating Current
VCT Volume ControlTank
VDC Volts Direct Current
Attachment